FOR IMMEDIATE RELEASE
Despite passing all exams and meeting every standard for graduation, NYPD recruit Emilio Andino remains in career limbo after his aunt, Lieutenant Quathisha Epps, filed a sexual harassment complaint against former Chief of Department Jeffrey B. Maddrey. The amended complaint reveals fabricated charges, racially biased drug testing, and institutional hypocrisy reaching the highest levels of NYPD leadership.
NEW YORK, NY 鈥� May 19, 2025 鈥� New York Civil rights attorney Eric Sanders, Esq. of 福利姬. has filed an Amended Verified Complaint in Emilio Andino v. City of New York, et al., asserting a detailed pattern of retaliation, racial and gender-based discrimination, and constructive discharge orchestrated by NYPD officials against a Black Police Academy recruit鈥攏ot for what he did, but for who he鈥檚 related to.
At the center of the case is Mr. Emilio Andino, a high-performing recruit assigned to Hook Company 24-56 at the NYPD Police Academy, whose aunt, retired Lieutenant Quathisha Epps, filed an EEOC Charge of Discrimination on December 21, 2024. The charge publicly accused then鈥揅hief of Department Jeffrey B. Maddrey of quid pro quo sexual harassment and systemic misconduct.
Within days, the NYPD allegedly began isolating and targeting Andino, culminating in a retaliatory suspension, fabricated disciplinary charge, racially discriminatory drug test, and career obstruction, despite Andino scoring a 93 on his final trimester exam and meeting all graduation and certification requirements.
鈥淭his is not discipline. This is retaliation by association,鈥� said Eric Sanders, Esq. 鈥淎nd the NYPD is using it to enforce silence across the department.鈥�
鈥淒ifferent Commissioner, Same Result鈥�: The Adams Administration鈥檚 Failure to Confront NYPD Retaliation
According to the amended complaint, Andino鈥檚 persecution occurred under four police commissioners鈥攁ll appointed by Mayor Eric Adams:
Keechant Sewell (2022鈥�2023), who took no public or internal action despite knowledge of growing tension between Maddrey and whistleblowers.
Edward A. Caban (July鈥揝ept. 2024), whose short tenure was marked by continued internal deference to command loyalty.
Thomas G. Donlon (Sept.鈥揘ov. 2024), a former FBI official who, according to the complaint, presided over a dramatic escalation of retaliation inside the Academy, failed to launch any internal reviews or corrective measures.
Jessica S. Tisch (appointed Nov. 2024), under whose leadership Andino was formally charged, drug tested without cause, blocked from graduation, and effectively abandoned in institutional limbo.
鈥淎ndino鈥檚 case shows what happens when leadership becomes a revolving door, but the machinery of retaliation never stops turning,鈥� Sanders said. 鈥淪ewell ignored it. Caban enabled it. Donlon was compromised. Tisch refused to act. And through it all, Mayor Adams stood at the helm, watching his department punish the innocent.鈥�
Racial Slurs, Sexualized Taunts, and a Staged Confrontation
The complaint describes a racially hostile and sexually charged atmosphere inside Hook Company 24-56. Fellow recruit Bahrons Asliev, who is Asian, allegedly directed racial slurs at Andino and made explicit remarks involving Andino鈥檚 12-year-old son.
On April 1, 2025, Asliev provoked a staged confrontation after a training scenario. Despite multiple witnesses, the NYPD failed to discipline Asliev and suspended Andino without pay.
Fabricated Charges and Scientifically Discredited Drug Testing
On May 9, 2025, Andino was formally charged under Department Advocate’s Office Serial No. C-033577, authored by Inspector Angel L. Figueroa and endorsed by Chief of Training Martine N. Materasso. The justification relied on a UF49 written by Deputy Inspector Arsenio Camilo, which allegedly omitted key details, excluded exculpatory witnesses (VERAS, BATISTA, SUAREZ), and distorted events.
Days earlier, on May 5, 2025, Andino was ordered to undergo radioimmunoassay of hair (RIAH) testing鈥攁 discredited methodology known to affect Black officers disproportionately. The complaint alleges that the test was neither random nor based on probable cause and was used solely as a retaliatory mechanism.
Despite the humiliation, Andino passed the test.
Top Exam Score, Still Blocked from Graduation
On May 15, 2025, Andino scored a 93 on his third and final trimester exam鈥攐ne of the highest in his class. By May 16, he had fulfilled all graduation and certification requirements.
Still, the NYPD refused to:
Graduate him,
Assign him to a field command,
Provide any explanation for his stalled progression.
The complaint asserts that Andino remains technically employed, but without status, advancement, or assignment鈥攁 form of constructive discharge by design.
Materasso and the Mob: Criminal Association, No Accountability
On May 14, 2025, two days before Andino learned of his exam score, Materasso was publicly photographed at Sobro Garden in the Bronx, socializing with Jimmy 鈥淛amie鈥� Rodriguez, an alleged associate of the Lucchese crime family.
The image was:
Posted on Instagram under the handle @iamjimmyrodriguez,
Time-stamped,
Geotagged to Sobro Garden, 26 Bruckner Boulevard in the Bronx.
The amended complaint cites statements from John Pennisi, a former Lucchese member turned government witness, who publicly identified Rodriguez as a Lucchese affiliate seeking formal induction.
Despite this clear violation of NYPD Administrative Guide 304-06(8)(c), a vaguely worded 鈥渃riminal association鈥� policy that prohibits officers from 鈥渒nowingly associating鈥� with individuals 鈥渞easonably believed鈥� to be engaged in criminal activity, no action was taken against Materasso.
鈥淲hile a Black recruit is drug tested and blocked from graduating, a white chief photographed with an alleged mob associate faces no consequences,鈥� Sanders said. 鈥淭hat鈥檚 not discipline. That鈥檚 institutional hypocrisy.鈥�
Maddrey鈥檚 Central Role and Pattern of Abuse
The complaint reserves particular condemnation for Maddrey, who retired in December 2024, just days after Epps鈥檚 complaint was filed and her story appeared in the press.
As Chief of Department, Maddrey:
Exercised ultimate control over training, discipline, and internal affairs.
Was directly aware of Epps鈥檚 allegations and their potential retaliation fallout.
Took no steps to prevent or mitigate foreseeable harm to her family.
The lawsuit characterizes Maddrey鈥檚 inaction as 鈥渁 tacit endorsement of reprisal.鈥�
It also highlights Maddrey鈥檚 history of misconduct, including:
A 2017 internal guilty plea for obstructing an investigation into an inappropriate sexual relationship with a subordinate.
Substantiated CCRB findings from multiple use-of-force complaints.
Recent lawsuits, including claims from Captain Gabrielle Walls and advocate Dana Rachlin, have alleged sexual harassment coverups, retaliation, and internal corruption.
Command-Level Ratification by Tisch and Kinsella
Tisch and First Deputy Commissioner Tania I. Kinsella are named for ratifying the retaliatory conduct under their authority as final policymakers under N.Y.C. Administrative Code 搂 14-115.
The complaint alleges they:
Had actual knowledge of the retaliation,
Took no corrective action,
Perpetuated a disciplinary structure that punishes association with whistleblowers.
Legal Claims and Relief Sought
The Amended Verified Complaint asserts violations of the:
New York State Human Rights Law (NYSHRL), and
New York City Human Rights Law (NYCHRL)
鈥ncluding claims for:
Race and gender discrimination
Hostile work environment
Retaliation and constructive discharge
Plaintiff seeks:
Compensatory and punitive damages
Declaratory judgment
Attorneys鈥� fees and costs
Graduation and reinstatement with a field assignment
Statement from Eric Sanders, Esq.
鈥淚nstitutional retaliation doesn鈥檛 always look like a demotion or a firing. Sometimes it鈥檚 quieter鈥攁 suspension, a bogus charge, a racially biased drug test, or simply stalling someone鈥檚 career until they give up. That鈥檚 what happened here. What鈥檚 more disturbing is that while they were punishing Emilio Andino for who he鈥檚 related to, they were protecting executives fraternizing with reputed mob figures. The public should know this is how the NYPD operates behind the curtain.鈥�
Call to Action
The NYPD鈥檚 retaliation machine has survived four commissioners and the full term of Mayor Eric Adams, but its tactics remain unchanged. Whistleblowers are punished, truth-tellers are silenced, and聽those closest to them are treated as collateral.
Emilio Andino’s case is not an isolated incident. It is part of a larger civil rights crisis within the NYPD鈥攐ne that calls for immediate oversight, public scrutiny, and structural reform.
鈥淭he message under Adams has been consistent,鈥� Sanders concluded. 鈥淚t鈥檚 never about reform. It鈥檚 about self-protection. And anyone鈥攅ven a young recruit鈥攚ho threatens that culture becomes expendable.鈥�
Case Information
Emilio Andino v. City of New York, et al.
Index No. 155113/2025
Supreme Court of the State of New York, County of New York
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Read the Amended Verified Complaint